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GAO-14-491R:
United States Government Accountability Office:
GAO:
441 G St. N.W.
Washington, DC 20548:
May 19, 2014:
The Honorable Carl Levin:
Chairman:
The Honorable James M. Inhofe:
Ranking Member:
Committee on Armed Services:
United States Senate:
The Honorable Howard P. "Buck" McKeon:
Chairman:
The Honorable Adam Smith:
Ranking Member:
Committee on Armed Services:
House of Representatives:
Defense Acquisitions: Update on DOD's Efforts to Implement a Common
Contractor Manpower Data System:
The Department of Defense (DOD), the federal government's largest
purchaser of contractor-provided services, reported that it obligated
about $187 billion--more than half of its total contract obligations--
on service contracts in fiscal year 2012. DOD relies on contractors to
perform functions as varied as professional and management support,
information technology support, medical services, and weapon system
and intelligence support. In recent years, Congress has enacted
legislation to improve DOD's ability to manage its acquisition of
services; to make more strategic decisions about the right workforce
mix of military, civilian, and contractor personnel; and to better
align resource needs through the budget process to achieve that mix.
For example, Section 2330a of title 10 of the U.S. Code requires DOD
to annually compile and, for the military services and defense
agencies to review, an inventory of services contracted for or on
behalf of DOD during the preceding fiscal year, in part, to help
provide better insight into the number of contractor full-time
equivalents (FTE) providing services to the department. Further, the
military services and defense agencies are required to use the
inventory to inform strategic workforce planning decisions, and DOD is
required to use the inventory to better align resource needs through
the budget process. Within DOD, the offices of the Comptroller and the
Under Secretaries of Defense for Acquisition, Technology, and
Logistics (AT&L), and Personnel and Readiness (P&R) have shared
responsibility for issuing guidance for compiling and reviewing the
inventory.
We have previously reported on DOD's efforts to compile and review its
inventory of contracted services, including initiatives to standardize
contractor manpower data collection across the department.[Footnote 1]
In January 2011, we recommended that DOD develop a plan of action to
facilitate the department's stated intent to collect contractor
manpower data and address other limitations.[Footnote 2] DOD
subsequently issued a plan in November 2011 to develop a common
technology solution that would allow the department to collectively
meet the inventory requirements. While the plan represented a step in
the right direction, it did not contain milestones or resources
needed, as we had previously recommended. In April 2012, we found that
DOD faced challenges in developing a common technology solution given
the different requirements of the military departments and the
remaining defense components.[Footnote 3] As an interim step, DOD
stated that it would establish a common data system for DOD components
to begin reporting data in time for the department's fiscal year 2013
inventory submission, but did not expect that components would fully
use the system for most of their contracts for services until fiscal
year 2016. In May 2013, we found that the department had taken steps
to implement interim data systems for the Air Force and Navy based on
the Army's Contractor Manpower Reporting Application (CMRA), but had
not implemented our 2011 recommendation.[Footnote 4] At that time, DOD
noted that it expected to field an interim data system that would be
shared by the remaining DOD components.
Section 951(b) of the fiscal year 2014 National Defense Authorization
Act mandated GAO to report on DOD's contractor inventory submissions
for fiscal years 2011 through 2015.[Footnote 5] This report (1)
provides information on DOD's contractor inventory for fiscal year
2012 and (2) addresses the status of DOD's efforts to implement a
common data system to capture contractor manpower data.
To provide data on the estimated contractor FTEs and dollars obligated
for contracted services in fiscal year 2012, we reviewed DOD's July
16, 2013 submission of its fiscal year 2012 inventory and interviewed
cognizant officials from P&R and the military departments who were
responsible for compiling the inventory. Our previous work identified
data limitations with DOD components using data from the Federal
Procurement Data System-Next Generation (FPDS-NG) as the basis for
their inventories.[Footnote 6] For example, FPDS-NG does not identify
more than one type of service in a contract, thus limiting its utility
for the purposes of compiling a complete and accurate inventory.
However, we found the data sufficiently reliable for our purposes of
providing information on the fiscal year 2012 inventory data DOD
reported.
To determine the progress DOD has made in developing a common
contractor manpower data system since our most recent report in May
2013, we reviewed DOD memoranda for compiling and reviewing its
inventories, and planning documents and guidance for establishing a
common system. We also interviewed officials from P&R and the
Departments of the Army, Air Force, and Navy to discuss progress
toward a common system and associated business processes. We focused
on the military departments as they accounted for the majority of
obligations and contractor FTEs DOD reported in the fiscal year 2012
inventory, which reflects the most current inventory data available.
We conducted this performance audit from March 2014 to May 2014 in
accordance with generally accepted government auditing standards.
Those standards require that we plan and perform the audit to obtain
sufficient, appropriate evidence to provide a reasonable basis for our
findings and conclusions based on audit objectives. We believe that
the evidence obtained provides a reasonable basis for our findings and
conclusions based on audit objectives.
Results in Brief:
Thirty-two DOD components submitted inventories for fiscal year 2012,
collectively reporting an estimated 670,000 contractor FTEs providing
services to DOD with obligations totaling about $129 billion. Since
our May 2013 report, DOD has taken additional steps to implement its
November 2011 plan to collect contractor manpower data via a
department-wide solution, but various challenges may hinder DOD's
efforts to having a common system and associated processes fully in
place to support its fiscal year 2016 inventory. In September 2013,
DOD fielded a system based on the Army's CMRA system to support the
other DOD components as it had previously done for the Air Force and
Navy. Each of the four CMRA systems is independent, maintaining its
own interface that requires a separate log-in, but all are accessible
via a common webpage. DOD is weighing options on how to further refine
the current CMRA configuration. These options include maintaining the
four independent CMRA systems or developing a single, unified system.
Further, DOD is determining the business processes and rules needed to
standardize the department's approach to collecting and using
inventory data. DOD officials noted that a key factor hindering
resolution of these issues has been the lack of dedicated resources to
develop and implement a common system and associated business
processes. In March 2014, DOD approved plans to establish an office to
support these implementation efforts, but the office's roles and
responsibilities and how it will be staffed have not been fully
determined.
Background:
Section 2330a of title 10 of the U.S. Code requires the Secretary of
Defense to establish a data collection system and to submit an annual
inventory of the activities performed pursuant to contracts for
services for or on behalf of DOD during the preceding fiscal year.
[Footnote 7] The inventory is to include a number of specific data
elements for each identified activity, including:
* the function and missions performed by the contractor;
* the contracting organization, the component of DOD administering the
contract, and the organization whose requirements are being met
through contractor performance of the function;
* the funding source for the contract by appropriation and operating
agency;
* the fiscal year the activity first appeared on an inventory;
* the number of contractor employees (expressed as FTEs) for direct
labor, using direct labor hours and associated cost data collected
from contractors;
* a determination of whether the contract pursuant to which the
activity is performed is a personal services contract; and:
* a summary of the information required by section 2330a(a) of title
10 of the U.S. Code.
As implemented by DOD, components are to compile annual inventories of
activities performed on their behalf by contractors and submit them to
AT&L, which is then required to formally submit a consolidated DOD
inventory to Congress no later than the end of the third quarter of
each fiscal year. Within 30 days after it is submitted to Congress,
the inventory is to be made public. Within 90 days of the date on
which the inventory is submitted to Congress, the secretaries of the
military departments and heads of the remaining defense components are
to complete a review of the contracts and activities for which they
are responsible and ensure that any personal services contracts in the
inventory were properly entered into and performed appropriately; that
the activities in the inventory do not include inherently governmental
functions; that to the maximum extent practicable, the activities on
the list do not include any functions closely associated with
inherently governmental functions; and that activities that should be
considered for conversion to DOD civilian performance have been
identified.[Footnote 8]
Section 2330a of title 10 of the U.S. Code also requires the
secretaries of the military departments or heads of the remaining
defense components responsible for activities in the inventory to
develop a plan, including an enforcement mechanism and approval
process, to:
* provide for the use of the inventory to make determinations
regarding the most appropriate mix of military, civilian, and
contractor personnel to perform its mission;
* ensure that the inventory is used to inform strategic workforce
planning;
* facilitate the use of the inventory for budgetary purposes; and:
* provide for appropriate consideration of the conversion of certain
activities, to include those closely associated with inherently
governmental functions, critical functions, and acquisition workforce
functions, to performance by government employees.[Footnote 9]
Section 2463 of title 10 of the U.S. Code requires the Secretary of
Defense to make use of the inventory of contracted services to
identify certain functions performed by contractors, to include
closely associated with inherently governmental functions, critical
functions and acquisition workforce functions, and ensure that special
consideration is given to converting those functions to civilian
performance.[Footnote 10]
Further, section 115b of title 10 of the U.S. Code requires the
biennial submission of a strategic workforce plan to shape and improve
DOD's civilian workforce. Among other requirements, the plan is to
include an assessment of the appropriate mix of military, civilian,
and contractor personnel capabilities. P&R is responsible for
developing and implementing the strategic plan in consultation with
AT&L. Section 235 of title 10 of the U.S. Code requires that the
Secretary of Defense include (in the budget justification materials
submitted to Congress) information that clearly and separately
identifies both the amount requested for the procurement of contract
services for each DOD component, installation, or activity, and the
number of contractor employee full-time equivalents projected and
justified for each DOD component, installation, or activity based on
the inventory of contracts for services and associated reviews.
[Footnote 11]
In addition, Section 129a of title 10 of the U.S. Code governs DOD's
general policy for total force management, requiring the Secretary of
Defense to establish policies and procedures for determining the most
appropriate and cost efficient mix of military, civilian, and
contractor personnel to perform the mission of the department. The law
states that these procedures shall specifically require DOD to use,
among other things, the inventory of contracted services compiled
under section 2330a of title 10 of the U.S. Code, when making
determinations regarding the appropriate workforce mix.
Collectively, these statutory requirements mandate the use of the
inventory and the associated review process to enhance the ability of
DOD to identify and track the services provided by contractors,
achieve accountability for the contractor sector of its total
workforce, help identify functions for possible conversion from
contractor performance to DOD civilian performance, support the
development of DOD's annual strategic workforce plan, and project and
justify the number of contractor FTEs included in its annual budget
justification materials.
Thirty-two DOD Components Submitted Contractor Inventories for Fiscal
Year 2012:
Thirty-two DOD components submitted inventories for fiscal year 2012,
collectively reporting an estimated 670,000 contractor FTEs providing
services to DOD with obligations totaling about $129 billion, as shown
in table 1.[Footnote 12] DOD has submitted annual inventories for
fiscal years 2007 through 2012, the most recent submitted on July 16,
2013, to reflect the fiscal year 2012 inventory.[Footnote 13]
Table 1: Estimated Number of Contractor Full Time Equivalents (FTEs)
and Obligations as Reported in DOD's Inventory of Contracted Services:
Fiscal year: 2008;
Estimated number of contractor FTEs: 655,000;
Total obligations[A]: $127 billion.
Fiscal year: 2009;
Estimated number of contractor FTEs: 767,000;
Total obligations[A]: $155 billion.
Fiscal year: 2010;
Estimated number of contractor FTEs: 623,000;
Total obligations[A]: $121 billion.
Fiscal year: 2011;
Estimated number of contractor FTEs: 710,000;
Total obligations[A]: $145 billion.
Fiscal year: 2012;
Estimated number of contractor FTEs: 670,000;
Total obligations[A]: $129 billion.
Source: DOD's inventory of contracted services.
Note: The changes in DOD's overall approach, in particular how DOD as
a whole reflected research and development services and the use of
different formulas for estimating contractor FTEs, among other
factors, affected the reported changes in inventory data from year to
year. Consequently, we and DOD officials agree that caution should be
exercised when making direct comparisons between fiscal years 2008
through 2012 inventory data. All FTE figures are rounded to the
nearest thousand.
[A] The Army's inventory data reflects total invoiced dollar amounts
rather than obligations.
[End of table]
According to P&R officials, for the fiscal year 2012 inventory DOD
components generally used the same compilation processes they employed
in the previous year to determine contractor FTEs, although the
approaches varied by component. To compile its inventory, the Army
relied on its CMRA system, a database that captures information on
labor-hour expenditures by function, funding source, and mission
supported on contracted efforts. CMRA captures data reported directly
by the contractors on services performed at the contract line item
level, including information on the direct labor dollars, labor hours,
total invoiced dollars, and the functions and mission performed. For
other data elements in its inventory, such as the funding source and
contracting organization, the Army relied on the Army Contract
Business Intelligence System (ACBIS) and updates from resource
managers, contracting officer's representatives, and other officials.
By contrast, the remaining components compiled their inventory
information primarily using the Federal Procurement Data System-Next
Generation (FPDS-NG), which is the federal government's central
repository for contract-related information, but it does not capture
data on contractor FTE information.[Footnote 14] To address this
limitation, DOD issued guidance in February 2013 that identified five
methodologies components could use--singularly or in combination--to
estimate or calculate the number of FTEs in their fiscal year 2012
inventory. These varying approaches, which include reporting
information collected from contract invoices and referencing
independent government estimates, can result in inconsistent reporting
on the number of contractor FTEs performing services on behalf of the
department. DOD officials cautioned against comparing inventory data
across fiscal years given the differences in the estimating formulas
and other factors.
DOD Took Additional Steps to Establish a Common Contractor Manpower
Data System, but Faces Challenges:
DOD has taken additional steps to implement its November 2011 plan to
establish a common data system to meet inventory requirements, but
various challenges may hinder DOD's efforts to meet its goal of having
the system and standardized business processes fully in place to
support its annual inventory submission beginning with the fiscal year
2016 inventory.
DOD Has Taken Steps to Establish a Common Data System:
In its November 2011 memorandum, DOD outlined plans to develop a
common system for components to capture contractor manpower data on
most of their services contracts. As an interim step, DOD noted that
it expected the common system to be operational in time to support the
fiscal year 2013 inventory but did not expect that components would
fully use the system to collect and report data until fiscal year
2016. To achieve a uniform approach to collecting contractor manpower
data, DOD issued additional guidance in November 2012 that reiterated
its goal for all components to report contractor manpower data using a
common system, which it termed the Enterprise-wide Contractor Manpower
Reporting Application, to support the fiscal year 2013 inventory
submissions. P&R officials told us that in September 2013, DOD fielded
an additional CMRA system for the remaining DOD components as it had
previously done for the Air Force and Navy. Each of the four CMRA
systems--for the Departments of the Air Force, Army, and Navy, and the
remaining defense components, respectively--is independent, has its
own interface that requires a separate log-in, but all are accessible
via a common webpage. The military departments have their own help
desk support; however, P&R officials noted that the help desk for the
remaining DOD components is not operational due to funding lapses.
Currently, each of the four independent CMRA systems captures over 20
reportable data elements that are grouped into four categories, though
the sources vary for some elements depending on the DOD component (see
table 2).
Table 2: DOD Contractor Manpower Reporting Application (CMRA) Data
Categories and Sources by Military Department:
CMRA data categories: Contract service;
Examples of information collected: Non-labor direct costs, labor
hours, and invoiced amounts;
Data Sources:
Army: Contractor, sub-contractor;
Air Force: Contractor, sub-contractor;
Navy: Contractor, sub-contractor.
CMRA data categories: Contracting activity;
Examples of information collected: Contracting office, whether the
action was competed and number of offers received;
Data Sources:
Army: Federal Procurement Data System-Next Generation (FPDS-NG), Army
Contract Business Intelligence System (ACBIS);
Air Force: FPDS-NG;
Navy: ACBIS, FPDS-NG.
CMRA data categories: Funding activity;
Examples of information collected: Funding source;
Data Sources:
Army: Defense Finance and Accounting Service, General Fund Enterprise
Business Systems;
Air Force: Commanders Resource Information System, Contracting Officer
Representative (COR);
Navy: ACBIS, FPDS-NG.
CMRA data categories: Requiring activity;
Examples of information collected: DOD component for whom work is
performed;
Data Sources:
Army: Resource Manager;
Air Force: COR;
Navy: Contractor, COR.
Source: GAO analysis of DOD data.
Note: According to DOD officials, the military departments use
accounting systems, contracting officer representatives and other
systems and acquisition personnel to corroborate the accuracy of the
data entered into CMRA. We did not include information on the fourth
CMRA for the other DOD components in this table, as we focused on the
three military departments.
[End of table]
While the Army has been reporting based on CMRA since 2007, P&R
officials stated that the remaining DOD components are now using CMRA
to varying degrees to collect data for the fiscal year 2013 contractor
inventory.[Footnote 15] To measure the extent to which components are
reporting data in these systems, DOD's March 2014 guidance for the
fiscal year 2013 inventory submission required components to specify
the percentage of their total contracts reported by contractors in their
respective CMRA systems and the extent to which the components used
these data to support their inventory submissions. DOD expects to
report on this usage beginning with the fiscal year 2013 inventory,
due by June 30, 2014.
Challenges May Hinder DOD's Efforts to Meet Its Goal:
In its November 2012 guidance, DOD expressed its commitment to
improving visibility into and accountability of contracted services in
accordance with legislative requirements by developing a common
system. However, the department faces challenges as it considers
options on the capability and features of the common system. For
example,
* DOD officials stated their goal is to establish an enterprise-wide
solution that consists of common hardware and software, but they
continue to weigh options on what the solution entails. For example,
DOD officials expect to begin transitioning to a single interface in
fiscal year 2015 so that users may access all four CMRA systems using
a single log-in. According to DOD officials, the department is still
considering whether to maintain the four existing CMRA systems or
develop a single, common system. Either approach will integrate
information from components’ existing contract writing, financial,
and other business information systems, which may pose further
challenges.
* DOD officials described another goal is to establish standardized
business processes and rules for collecting, reporting, and fully
utilizing inventory data. However, DOD is determining the processes
and rules needed to govern the use of the common system. For example,
the Army collects data for contracted services from both service
contracts and contracts for supplies that have services provided under
such contracts, but P&R officials cited system limitations and other
factors as hindrances that limit the other DOD components' ability to
do so. AT&L and the Office of the Comptroller are taking steps to
address these limitations, according to P&R officials. Further, DOD
officials noted that they are in the early stages of developing
guidance on how the data will be used to prepare its annual contractor
inventory submission to Congress, to support the components' inventory
review process, and to help inform budget and workforce planning
decisions. The Army has a centralized approach to review its inventory
and inform its projections of contracted services, but a similar
approach has not yet been adopted across DOD. As DOD moves forward
with implementing the common data system, the department plans to
incorporate these business processes within a forthcoming DOD
Instruction on services acquisition; however, the department has not
yet established a timeframe for doing so.
DOD officials noted that a key factor hindering resolution of these
issues has been the lack of dedicated resources to develop and
implement a common system and associated business processes. P&R
officials stated that there is a working group comprised of members
from P&R, AT&L, the Office of the Deputy Chief Management Officer, and
other stakeholders. They noted, however, the need for dedicated
support for the effort. To ensure sustained management attention, in
September 2013 P&R prepared a request to establish the Total Force
Management Support Office, which DOD approved in March 2014. According
to P&R officials, this office is authorized and funded for six FTEs
and the department is in the process of finalizing a memorandum of
agreement that broadly outlines the office's roles and
responsibilities. DOD officials anticipate that the new office will
coordinate the department's efforts to define business processes for
compiling, reviewing, and using the inventory.
P&R officials noted that the ability to achieve the department's goal
of having all components report using the common data system is
predicated upon their assumptions that the office will be staffed by
June 2014 by experts within the Army's Office of Manpower and Reserve
Affairs, who currently manage the Army's CMRA system as well as its
inventory review process and added that if the Army experts do not
transfer, the new office would need to hire new staff who may lack
the desired expertise. According to DOD officials, further delays in
reaching agreement on the roles and responsibilities of the new office
may jeopardize the department's plan to implement the common system
in support of DOD's goal of full implementation by fiscal year 2016.
DOD continues to make headway in its efforts to develop a common data
system, but it is also encountering challenges that may adversely
affect its ability to achieve its goal of having all components
collect and report data using the system by fiscal year 2016. DOD's
current solution to these challenges is to create a new office to help
provide additional management attention and dedicated resources, but
it has not yet reached agreement on the office's roles and
responsibilities and it is uncertain when the office will be fully
staffed. Doing so in a timely fashion will be key to successfully
implementing the common data system. Further, DOD does not have a
comprehensive plan with timeframes and milestones to measure its
progress toward developing a common contractor manpower data system
that includes associated business processes. Developing such a plan,
as we previously recommended, would provide a tangible step in
implementing a common data system and using contractor manpower data
as part of workforce planning and budgeting decisions.
Agency Comments:
We are not making any recommendations in this report. In written
comments on a draft of this report, DOD agreed with our assessment
that challenges remain in establishing a common system to collect
contractor manpower data and reiterated the importance of establishing
a centralized office to manage the effort. DOD's written response is
reproduced in enclosure I.
We are sending copies of this report to the Secretary of Defense and
interested congressional committees. This report will also be
available at no charge on our Web site at [hyperlink,
http://www.gao.gov].
Should you or your staff have questions concerning this report, please
contact me at (202) 512-4841 or at dinapolit@gao.gov. Contact points
for our Offices of Congressional Relations and Public Affairs may be
found on the last page of this report. Key contributors to this report
include Candice Wright, Assistant Director; MacKenzie Cooper, Susan
Ditto, Jessica Drucker, John Krump, Caryn E. Kuebler, and Jean McSween.
Signed by:
Timothy J. DiNapoli:
Director, Acquisition and Sourcing Management:
Enclosure:
[End of section]
Footnotes:
[1] GAO, Defense Acquisitions: Continued Management Attention Needed
to Enhance Use and Review of DOD's Inventory of Contracted Services,
[hyperlink, http://www.gao.gov/products/GAO-13-491] (Washington, D.C.:
May 23, 2013); GAO, Defense Acquisitions: Further Actions Needed to
Improve Accountability for DOD's Inventory of Contracted Services,
[hyperlink, http://www.gao.gov/products/GAO-12-357] (Washington, D.C.:
Apr. 6, 2012); GAO, Defense Acquisitions: Further Action Needed to
Better Implement Requirements for Conducting Inventory of Service
Contract Activities, [hyperlink,
http://www.gao.gov/products/GAO-11-192] (Washington, D.C.: Jan. 14,
2011).
[2] [hyperlink, http://www.gao.gov/products/GAO-11-192].
[3] [hyperlink, http://www.gao.gov/products/GAO-12-357].
[4] [hyperlink, http://www.gao.gov/products/GAO-13-491].
[5] Pub. L. No. 113-66, § 951(b) (2013).
[6] [hyperlink, http://www.gao.gov/products/GAO-13-491].
[7] 10 U.S.C. § 2330a.
[8] 10 U.S.C. § 2330a(e). Inherently governmental functions, as a
matter of policy, are so intimately related to the public interest as
to require performance by government employees and include functions
that require discretion in applying government authority or value
judgments in making decisions for the government. Section 7.503(c)
of the Federal Acquisition Regulation provides examples of such
functions. In addition, closely associated with inherently
governmental functions are those that while not inherently
governmental, may approach the category because of the nature of the
function, the manner in which the contractor performs the contract,
or the manner in which the government administers performance under
a contract. Section7.503(d)of the Federal Acquisition Regulation
provides examples of such functions.
[9] 10 U.S.C. § 2330a(f).
[10] 10 U.S.C. § 2463(d).
[11] 10 U.S.C. § 235(b).
[12] As we previously reported, the service contract obligations
reported in the inventory of contracted services for a given fiscal
year may not match the amount of contract obligations from FPDS-NG, in
part because the FPDS-NG obligation amount for services captures
categories of services that are not reported in the inventory. See
[hyperlink, http://www.gao.gov/products/GAO-13-491].
[13] The fiscal year 2007 inventory only represented Army services
contracts.
[14] We have previously found that FPDS-NG may not capture other
statutorily-required data such as the requiring activity whose
requirements are met through the contract and does not include the
ability to identify more than one type of service in a contract, which
limits its utility for the purposes of compiling a complete and
accurate inventory. See [hyperlink,
http://www.gao.gov/products/GAO-11-192].
[15] The four defense intelligence agencies--Defense Intelligence
Agency, National Geospatial-Intelligence Agency, National Security
Agency, and National Reconnaissance Office--are excluded from the DOD
requirement to report contractor manpower data in CMRA as the system
does not have the capability to securely capture classified data.
[End of section]
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E-mail: fraudnet@gao.gov;
Automated answering system: (800) 424-5454 or (202) 512-7470.
Congressional Relations:
Katherine Siggerud, Managing Director, siggerudk@gao.gov:
(202) 512-4400:
U.S. Government Accountability Office:
441 G Street NW, Room 7125:
Washington, DC 20548.
Public Affairs:
Chuck Young, Managing Director, youngc1@gao.gov:
(202) 512-4800:
U.S. Government Accountability Office:
441 G Street NW, Room 7149:
Washington, DC 20548.
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